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Re: E-M:/ Sierra Club does not support Jeffords bill



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Enviro-Mich message from "Julie Griess" <jgriess@provide.net>
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Here's what I found at
http://tamalpais.sierraclub.org/policy/conservation/trading.html

Sierra Club Conservation Policies
Pollution Trading Policy
 The following policy on pollution trading has been adopted by the Sierra
Club Board of Directors February 20-21, 1999.
Pollution Trading

The Sierra Club opposes use of trading. In all cases, if a program is
initiated, there must be full public notice, disclosure, participation,
oversight, accountability, verification, and effective enforcement, with
rights of appeal for affected citizens and administrative and judicial
remedies.

The following conditions must apply:

(1) that the trade produces overall gains in ambient environmental
conditions;

(2) that such gains satisfy goals set forth in approved government plans;

(3) that reductions for trades are beyond current legal requirements, with
indicated reductions being greater than 1:1 as a hedge against uncertainty
and non-compliance;

(4) that the required reductions be new (e.g., not be taken from unused
allowances);

(5) that trading should be limited to pollutants of the same kind;

(6) that no credit be granted for reductions from sources closed down prior
to the proposal for the trade;

(7) that the trade occur within the same local physiographic unit (e.g.,
watershed or airshed), except that for the purposes of carbon dioxide, the
entire atmosphere is the
airshed*; ----------------------------------------------

*However, a CO2 trade should not be allowable if air quality could be
worsened locally or regionally as a result of the trade (because of
associated pollutants such as NOx). [That outcome would violate various
other provisions of this policy (e.g., it would like run afoul particularly
of either #1, C, or D.).] -----------------------------------------------

(8) that in all cases monitoring be provided by the seller, with results
reported to regulators and made public, to assure that the required
reductions actually occur; increased costs to the public of surveillance
should be covered by permit fees;

(9) that data on these reductions is provided to the public in an easily
understood format (electronically as well as in hard copy);

(10) that whoever cheats be punished by severe fines that are applied
automatically and that surety bonds be provided, where appropriate, as an
incentive to perform; and that buyers who rely on unwarranted credits also
be subject to fines;

(11) that information on violations remain public information and not be
subject to "audit privilege" or other forms of confidential business
information; and that compliance records for all firms engaging in trading
be made available to any member of the public (and not be subject to "audit
privilege"), including records on inspections and violations;

(12) that violators will have their allowable releases reduced in the year
following the violation by the amount of their excess releases; where the
amount of this excess is unknown, it should be assumed to be the maximum
physically possible;

(13) that the trader be competent to make the required reductions and that
firms that have contributed materially to ambient problems not be eligible
to engage in trading;

(14) that chronic cheaters be excluded from trading programs;

(15) that the government retain the right to further limit allowable
releases, without needing to compensate the releasor. Permission to trade
must not establish a right to pollute, nor any property interest in material
that is released.

Under no circumstances should trading arrangements lead to the following:

A. Violation of ambient standards, expanded pollution at grandfathered sites
(i.e., from old sites granted legal exemption from meeting standards), nor
significant deterioration in the quality of air and water which has been
good, nor degradation of soils, ecosystems or other public values;

B. Increased releases of any of the following categories of toxics (measured
at the point of release): -- heavy metals -- neurotoxins -- known or
suspected carcinogens -- known or suspected endocrine disrupters -- known or
suspected mutagens, or -- persistant or bioaccumulative agents;

C. Backsliding on pollution control obligations, nor on best management
practices, nor facilitate irresponsible conduct;

D. Build up of levels of pollution in Clean Air Act non-attainment areas,
nor make conditions worse in such areas;

E. Monopolization of pollution allowances;

F. Trading in, and between, communities that disapprove of trades that
affect them. Trading should never proceed without assessing the cumulative
impact on communities subject to trading that involves multiple sources;
public review and participation should be provided.

G. That any community be disproportionately burdened by the results of the
trade, especially those communities that are already disproportionately
burdened by toxics, or other noxious land, water or air pollutants.




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